BIS extends deadline/trigger date for “authorized/approved IC designer” status under ECCN 3A090.a Note 1 to December 31, 2026

BIS issued a final rule amending the Export Administration Regulations (EAR) by revising Note 1 to ECCN 3A090.a (Supplement No. 1 to 15 CFR Part 774) to replace the date “April 13, 2026” with “December 31, 2026” in paragraphs a.(2) and a.(3). This extends the trigger date for “authorized integrated circuit (IC) designer” status and the application deadline to become an “approved IC designer,” which affects how exporters can use/qualify for pathways intended to address presumptions and licensing posture for certain advanced logic integrated circuits controlled under ECCN 3A090.a. Compliance teams should update internal procedures, eligibility planning, and any supplier/customer communications keyed to the prior April 2026 deadline.